In recognizing fatigue as a safety issue, ICAO SARPS requires States to establish prescriptive flight and/or duty limitations regulations for aircrew. They should be designed to maintain an acceptable level of safety performance in the majority of situations.
In a prescriptive approach to fatigue management, the operator is expected to schedule within the prescribed limits, according to their specific context and to the risks that generate fatigue within their operation. The effectiveness of their scheduling practices is then monitored as part of their SMS. Through their oversight practices, the State ensures that the operator is managing their fatigue risk to an acceptable level within the constraints of the prescriptive limitations and requirements using existing SMS processes.
COVID-19 requirements within the changing operational environment mean it is even more important that these risks are managed to an acceptable level of safety as airline operations develop into a "new normal" approach.
Operators are still required to:
- retain records of work and non-work periods, including planned and actual work and non-work periods, with significant deviations from prescribed limits and minima recorded;
- publish an individual's work schedules sufficiently in advance to allow planning for work and rest periods;
- take steps to keep changes at short notice to a minimum and to minimize their impact;
- actively manage the assignment of unscheduled duties through operational processes and procedures. The focus should be on:
- minimizing the extent of disruption to the timing of a planned duty;
- providing protected sleep opportunities (prior to, during and after unscheduled duties);
- identifying minimal notification periods for changes to planned duties; and
- limiting the number of consecutive days that they may be subject to being assigned unscheduled duties.
